Last Updated: ………….. 2021
This page contains the information gathering and use policies adopted by One Plus Business Centre (“One Plus Business Centre“, “we“, “us“, “our“) in connection with this website (the “Site“). References to “you” and “your” are references to a user of our Site.
We are committed to protecting and respecting your privacy and handling your information in an open and transparent manner. We encourage you to read the following carefully to understand our views and practices regarding your personal information and how we will treat it. Please bear in mind that this Policy Statement is subject to review at any time. Please refer to updates to privacy statement section for further information.
In this Privacy Statement, your personal data is sometimes called “information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as “processing” such personal data.
In this Privacy Statement the term “Data Protection Legislation” means the EU General Data Protection Regulation 2016/679, together with all other applicable legislation relating to privacy or data protection.
For the purposes of Data Protection Legislation the data controller is One Plus Business Centre.
- What personal data do we collect?
- How do we collect your personal data?
- Sensitive personal data
- How do we use your personal data?
- Legal grounds for using your personal data
- Provision of information to third parties
- Third Party Links
- Data retention
- Keeping your information safe
- Your Legal Rights
- Children’s privacy
- Opting Out
- Updates to privacy statement
1. What personal data do we collect?
Personal data means any information about an individual from which that person can be identified. We may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Legislation and as set out in this Privacy Statement.
We may collect, store and process different kinds of personal data about you through a variety of different ways and for different purposes. These include the following:
- Identity Data includes first name, maiden name, last name, date of birth.
- Contact Data includes email address, home address and telephone number.
- Technical Data includes internet protocol (IP) address, browser type, version and language, internet service provider, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site.
- Usage Data includes information about how you use our Site.
If we speak to you over the phone or video call, you may provide us with personal data during the call. Such calls may be recorded for quality purposes. You will be informed at the outset of a call if it is to be recorded, giving you the opportunity to end the call if you are not comfortable with recording.
If you visit our premises in which we have installed CCTV, we may record footage of you.
Your personal information is necessary to enable us to deal with your enquiry, but additional information may be requested to help us to provide the most appropriate response. If such additional information is requested, it is highlighted and its provision is voluntary.
2. How do we collect your personal data
The personal data that we may collect about you broadly falls into the following categories:
Information that you provide voluntarily from direct interactions with us: When you register with us, use our services, submit a subscription request (e.g. to receive a newsletter or for marketing information), make an enquiry (either by submitting an online enquiry form or by corresponding with us by phone, e-mail or otherwise), you may be asked to provide some personal information such as your name and contact details (including telephone number, home address, date of birth and email address). We do not require registration for access to the Site in general but you may be asked to register to access certain areas. We may also, from time to time while you are accessing the Site, request you to complete a survey form which may relate either to your use of the Site and/or information posted on the Site.
Information that we collect automatically: When you visit our website, we collect automatically technical data about your visit including protocol (IP) address, browser type language and version, internet service provider, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site.
This information may be aggregated to provide statistical information about the users of our Site. No individual user will be identifiable from such information, which is used to ensure the Site reflects the needs of users. Whilst IP addresses may be categorised as personal information, we do not use this data to track your session.
We may also automatically collect and process information about your visit to our Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
Some of this information may be collected using cookies and similar tracking technology. For detailed information on the cookies we use and the purposes for which we use them, see the Cookies section below.
3. Sensitive Personal Data
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). You should only provide this information if it is required in response to a mandatory question on our contact form, or if you are otherwise content for us to process this information in accordance with the terms of this Privacy Statement. Where you do provide sensitive information this will be accepted as explicit consent to us to use that information in connection with the purpose for which it has been provided.
5. How we use your personal data
Our primary purpose in collecting user information is to provide you with a safe, smooth, efficient, and customised experience and to provide the services you have requested. We may also use the information that you have provided to ensure that the content on our Site is presented in the most effective manner for you and your computer.
We use your information for the following specific purposes:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to notify you about changes to our service;
- to ensure that content from our Site is presented in the most effective manner for you and for your computer;
- to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- as part of our efforts to keep our Site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to send you our newsletter or updates, or to make suggestions and recommendations to you and other users of our Site about services that may interest you or them; and provide you or them with targeted marketing in relation to our services (unless you or they indicate at any time that you or they do not wish us to do so); and
- when requesting material or asking someone to contact you, you will have the option to request other information that may be of interest.
6. Legal grounds for using your personal data
We will only use your personal data when the law allows us to. Most commonly, we will process your personal data when such processing is:
- performed after your explicit consent; or
- necessary for the purposes of the legitimate interests that we pursue, e.g. providing the services on our Site, to discharge our legal obligations, to store and disclose information where necessary and to evaluate, develop and improve our services and your interests and fundamental rights do not override those interests; or
- necessary for the performance of a contract with you; or
- necessary in order to comply with a legal obligation to which we are subject.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that personal data; (ii) you have made the personal data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.
7. Provision of information to third parties
Information is normally only provided to a third party if it is required in order to deal with your enquiry, but there may be other circumstances where it is necessary for us to provide information, including as a result of legal or regulatory process.
The following categories of recipients may receive your personal information and process it for the purposes outlined in this Privacy Statement:
- third party companies, agents, contractors, service providers or related companies, if this is necessary to provide you with our products and services, respond to your enquiries or for any other related purposes;
- analytics and search engine providers that may assist us in the improvement and optimisation of our Site;
- third parties who support our information technology or handle mailings or events on our behalf;
- law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site, our technology assets or the rights, property or personal safety of any person);
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity; and
- any successor in interest, in the event of our liquidation or administration.
- we do not undertake marketing activities for third parties, nor do we provide information to third parties for their own marketing purposes.
8. Third Party links
This Privacy Statement does not apply to other websites, operated by third parties. Our Site may provide links to third-party websites and if you access those links, this Privacy Statement does not apply as we do not control these third-party websites and we are not responsible for their privacy statements. This Privacy Statement relates only to information contained on, or gathered via, the Site.
9. Data Retention
We will only keep the personal data we collect about you, through your use of the Site or otherwise, for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
10. Keeping your information safe
We take your online security seriously and have implemented generally accepted standards of technology and operational security to protect your personal information from loss, misuse, alteration or destruction. Once we have received your information we will ensure that the collection and use of it is in accordance with Data Protection Legislation. All personnel of One Plus Business Centre is required to keep personal information confidential and only authorised persons have access to such information.
Please note, however, that the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your personal information transmitted to us or provided though the Site.
Data that you submit via our Site is sent to and stored on secure servers in Microsoft Azure.
Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), to a country not deemed to provide adequate protection of your information by the European Commission, and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers, related companies, agents or contractors. Such transfers may be made in order to improve our Site or to assist in our security or fraud protection activities.
When we, or our permitted third parties, transfer your information outside the European Economic Area, we or they will impose contractual obligations on the recipients of that data to protect your information to the standard required in the European Economic Area. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. We do not generally rely on your consent as the legal basis for transferring your personal data outside the EEA, however where we feel it is necessary or appropriate we may seek to rely on your consent as the legal basis for such processing. Where we do, you may withdraw your consent at any time in the manner described below.
11. Your legal rights
At any time, you have the right:
- to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from whom it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
- to request access to or a copy of any personal data which we hold about you;
- to rectification of your personal data, if you consider that it is inaccurate;
- to ask us to delete your personal data, if you consider that we do not have the right to hold it;
- to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- to ask us to stop or start sending you marketing messages (e.g. our newsletter) at any time by using the below contact details;
- to restrict processing of your personal data;
- to data portability (moving some of your personal data elsewhere) in certain circumstances;
- to object to your personal data being processed in certain circumstances; and
- not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.
12. Children’s privacy
This Site is not intended for children and we do not knowingly collect data relating to children. We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities.
If you no longer wish to receive our newsletters and/or promotional communications, you have the option of “unsubscribing” from our mailing list for newsletters, alerts and updates at any time, thereby disabling any further such e-mail communication from being sent to you. To unsubscribe you can send us an email at firstname.lastname@example.org. In addition, each electronic mailing we send you will contain details of how you can unsubscribe by clicking on the ‘unsubscribe’ link in the email. Please note that it may take up to one month to action your request.
If you have any concerns or questions about the security of our Site, this Privacy Statement or any personal information we collect from you, please do not hesitate to contact our Data Protection Officer at DPO@……………………….net. Additionally, if you have any concerns about our use of your information, you also have the right to make a complaint to the Data Protection Commissioner’s Office, which regulates and supervises the use of personal data in Cyprus:
1 Iasonos str., 1082 Nicosia
P.O.Box 23378, 1682 Nicosia
Tel: +357 22818456
Fax: +357 22304565
15. Updates to Privacy Statement
This Privacy Statement is subject to periodic review, taking account of applicable data protection regulations. All amended terms automatically take effect on the date they are posted on this Site, unless otherwise specified.
You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Privacy Statement.
We encourage you to read this Privacy Statement carefully and revisit this page from time to time to review any updates.